Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Challenge to the warrant of authorization raised identical legal contention already admitted before a tribunal and pending as an appeal in another High Court; applying the abstention principle for parallel proceedings, the High Court declined to entertain a fresh writ on the same controversy and dismissed the petition while granting liberty to seek framing of an additional substantial question of law in the pending appeal. The outcome turns on duplicative litigation and preservation of appellate remedy rather than re examination of the authorization on merits.
Challenge to the warrant of authorization raised identical legal contention already admitted before a tribunal and pending as an appeal in another High Court; applying the abstention principle for parallel proceedings, the High Court declined to entertain a fresh writ on the same controversy and dismissed the petition while granting liberty to seek framing of an additional substantial question of law in the pending appeal. The outcome turns on duplicative litigation and preservation of appellate remedy rather than re examination of the authorization on merits.
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